CBAM deadlines for 2026 and 2027: what happens and when

2026 certificate-price publication schedule

The European Commission’s price page lists four publication dates for the 2026 quarterly records. As reviewed on 11 August 2026, Q1 and Q2 are published; Q3 and Q4 remain scheduled. These are publication events, not certificate-purchase deadlines.

2026 imports establish the first certificate cycle

The definitive period began on 1 January 2026. Certificates are not sold during 2026, but the year's covered imports and embedded emissions feed the first annual declaration and surrender in 2027.

For 2026 imports, the applicable price is the quarterly 2026 price for the quarter in which the goods were imported. From 2027, normal certificate prices are calculated and published weekly; a later weekly price should not replace the historical import-quarter price.

1 February 2027 — certificate sales start

From 1 February 2027, Member States sell CBAM certificates through the common central platform to authorised CBAM declarants established in their territory under Article 20.

The sales start is not a surrender deadline and does not by itself decide how many certificates an account needs.

2027 quarter ends — the 50 % holding rule

From 2027, Article 22 requires the authorised CBAM declarant's registry account at each quarter end to hold certificates corresponding to at least 50 % of cumulative embedded emissions in goods imported since the start of that calendar year, using the bases and free-allocation adjustment specified in the Regulation.

If a declarant exceeds the single mass-based threshold during the year, Article 22(2a) requires it to meet that holding obligation by the end of the following quarter. The ordinary quarter-end wording should not erase that first-compliance timing rule.

This is an in-year account-balance requirement, not the annual surrender, not 50 % of an estimated monetary cost, and not a rule that one separate purchase must be made every quarter.

30 September 2027 — first declaration and surrender

By 30 September 2027, the authorised CBAM declarant submits the first annual CBAM declaration for calendar-year 2026 imports and surrenders the corresponding certificates. Declaration and surrender share the date but remain distinct actions under Articles 6 and 22.

The surrender number follows the declared embedded emissions after the permitted carbon-price-paid and free-allocation adjustments. A published price or planning estimate is not that certificate number.

31 October 2027 — repurchase request window

After surrender, an authorised CBAM declarant may request repurchase of eligible excess certificates by 31 October. The general Article 23 cap is the number the declarant was obliged to purchase under Article 22(2) during the calendar year of purchase. All certificates bought because the declarant expected to exceed the single mass-based threshold must be repurchased on request if that threshold was ultimately not exceeded. Repurchase uses the price paid for each eligible certificate, and certificates bought in 2027 for 2026 emissions may only be repurchased in 2027.

1 November 2027 — special first-cycle cancellation

On 1 November 2027, certificates purchased in respect of 2026 embedded emissions and still remaining in the account are cancelled without compensation under Article 24. This does not mean every certificate purchased in 2027 is cancelled.

Cancellation is suspended to the extent of the disputed amount while a Member-State dispute over the number to surrender is pending. That statutory exception belongs with the date.

Calendar-only example: imports in two quarters

Northstar Metals GmbH is a synthetic EU importer with covered steel imports in Q1 and Q3 2026. It records the import quarter for each goods line, preserves the matching quarterly price basis, and keeps the first 2027 declaration and certificate actions as separate calendar events.

Its calendar shows sales from 1 February 2027; declaration and surrender as separate actions on 30 September; an optional eligible repurchase request by 31 October; and the special first-cycle cancellation on 1 November, subject to the pending-dispute exception. If Northstar also imports covered goods during 2027, the separate quarter-end holding rule applies to those cumulative 2027 imports.

This calendar-only example does not calculate a certificate count or liability and does not decide which rules apply to a specific importer.

Common CBAM deadline mistakes to avoid

A useful internal calendar labels the event, import period, responsible actor, official source, and current status. That prevents five recurring mistakes:

• Treating a 2026 quarterly price publication as a certificate-purchase deadline; certificates are not sold during 2026.
• Applying a 2027 weekly price to goods imported during 2026 instead of preserving the relevant 2026 import-quarter price.
• Treating the 2027 quarter-end 50 % holding balance as the annual surrender or as 50 % of an estimated monetary cost.
• Dating the first annual declaration to 2026: it covers 2026 imports and is not due in 2026; the adopted deadline is 30 September 2027.
• Turning draft platform request, payment, processing, or fee mechanics into settled instructions before a final act is published.

Draft platform operations are not another adopted deadline

The Commission published a draft delegated regulation on 9 July 2026 for detailed sale and repurchase operations. The initiative currently labels it ‘In preparation’; its feedback period closed on 6 August 2026, and the page does not show a final adopted act.

The draft delegated regulation is not an adopted act. Proposed request, payment, processing, and fee mechanics should not be treated as settled deadlines or encoded in a calculator.

Use the planner and lifecycle guide together

The deadline planner keeps the dated events source-linked. The certificate lifecycle guide explains what each event means, and the price tracker shows the official price records without turning them into a certificate order or final liability.